20170536 Ver 2_WRC Comments_20190204

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
February 4, 2019
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: EFA Properties Shoreline Stabilization
Lake Toxaway, Transylvania County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to remove fill along approximately 200 feet of shoreline on Lake Toxaway in
Transylvania County and construct a boulder wall behind this wall to restore the shoreline to its
original dimensions. This application addresses a NC Division of Water Resources Notice of
Violation regarding the unauthorized fill. Our comments on this application are offered for your
consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish
and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
The project should not harm trout and construction does not need to be avoided during the trout
moratorium. Natural cover such as boulders and large fallen trees provide spawning and rearing
habitats for sunfish, black bass, and other fishes in the lake, and it is important to maintain and
restore as much of this habitat as possible.
The application proposes to use the existing boulder wall as a coffer dam and remove the fill
from behind it to the location of the former shoreline. Then a stacked boulder wall will be
constructed to secure the shoreline, using sticks and woody debris between one of the boulder
rows in order to provide cover for fish. We support this creative solution to providing fish cover
within the structure. We also recommend placing a riprap lining the base of the boulder wall, as
this will further increase physical shoreline complexity for fish and invertebrates that is not
afforded by a boulder wall. Riprap also dissipates wave energy and thereby helps prevent
structures from undermining and collapsing.
We offer the following recommendations to minimize impacts to wildlife:
1. Install a rip rap apron at the base of walls in order to provide habitat complexity.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

EFA Properties Shoreline Stablization Page 2 February 4, 2019
L. Toxaway, Transylvania Co
2. Leave any fallen trees or other large woody debris in place or moving it temporarily and
replacing it after the stabilization work is complete.
3. We recommend that the landowner plant as many native shoreline trees and shrubs as
possible, as they not only stabilize banks but also serve as habitat for wildlife such as song
birds.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Andrew Bick, Headwaters Engineering
Kevin Mitchell, NC Division of Water Resources